Returning 2019 RMD under CARES ACT – July 15 deadline?
Question for the community:
First RMD for client eligible to be taken in 2019. Client wanted to defer first RMD until 1st qtr 2020. 2019 RMD was taken in March 2020. Now, we are considering returning the RMD due to CARES Act. I see in May’s “IRA Advisor”, guidance from the IRS that if you received a distribution between February 1, 2020 and May 15, 2020, you have until July 15, 2020 to roll it over. My question, is does this only apply to 2020 RMDs, or also 2019 RMDs taken in Feb – May 2020?
Thank you for your insight and answers.. they are much appreciated.
Permalink Submitted by Alan - IRA critic on Tue, 2020-06-02 02:47
If the client’s RBD was 4/1/2020, any 2019 RMD taken in 2020 is not required and therefore eligible for rollover. Client has until 7/15/2020 to roll over this distribution, however subject to the one rollover per 12 month limitation. If not eligible for rollover due to the one rollover limit, this distribution can only be rolled over if client qualifies for a CRD (corona virus related distribution).